6 N.Y.3d 744 (2005)
A defendant pleading guilty to a determinate sentence must be aware of the post-release supervision component of that sentence in order to knowingly, voluntarily, and intelligently choose among alternative courses of action.
Summary
Tammi Van Deusen pleaded guilty to first-degree robbery in exchange for a sentence of 5 to 15 years. Prior to sentencing, she moved to withdraw her plea, arguing the court failed to advise her she would be subject to mandatory post-release supervision (PRS). The County Court denied her motion, and the Appellate Division affirmed, noting that her actual prison term plus PRS was less than the agreed-upon maximum. The New York Court of Appeals reversed, holding that the failure to advise Van Deusen of the PRS component invalidated her guilty plea, regardless of whether the combined sentence was less than the agreed-upon maximum because a defendant must be fully aware of all direct consequences of a guilty plea.
Facts
Tammi Van Deusen was indicted on several charges, including felony murder, burglary, robbery, criminal use of a firearm, and conspiracy, related to a home invasion where a victim was killed. She pleaded guilty to first-degree robbery in exchange for a determinate sentence between 5 and 15 years. Prior to sentencing, Van Deusen moved to withdraw her guilty plea because the County Court did not inform her that she would be subject to mandatory post-release supervision (PRS) after her release from prison.
Procedural History
The County Court denied Van Deusen’s motion to withdraw her guilty plea and sentenced her to eight years’ imprisonment plus five years of PRS. The Appellate Division affirmed the County Court’s decision, concluding that Van Deusen was not deprived of the benefit of her plea bargain because the total period of punishment (imprisonment plus PRS) was less than the maximum 15 years she had agreed to. The New York Court of Appeals granted Van Deusen leave to appeal.
Issue(s)
Whether a guilty plea to a determinate sentence is knowing, voluntary, and intelligent when the defendant is not informed of the mandatory post-release supervision component of the sentence, even if the total period of punishment (imprisonment plus PRS) is less than the agreed-upon maximum period of incarceration?
Holding
No, because a defendant pleading guilty to a determinate sentence must be aware of the post-release supervision component to make a knowing, voluntary, and intelligent choice among alternative courses of action.
Court’s Reasoning
The Court of Appeals relied on its prior holding in People v. Catu, 4 N.Y.3d 242 (2005), which established that post-release supervision is a direct consequence of a conviction for a violent felony offense with a determinate sentence. The court emphasized that a defendant must possess all necessary information for an informed decision when choosing to plead guilty. The failure to inform Van Deusen of the mandatory PRS meant she did not have all the information necessary for an informed choice. Therefore, her decision to plead guilty could not be considered knowing, voluntary, and intelligent. The Court stated that “Because a defendant pleading guilty to a determinate sentence must be aware of the postrelease supervision component of that sentence in order to knowingly, voluntarily and intelligently choose among alternative courses of action, the failure of a court to advise of postrelease supervision requires reversal of the conviction.” The court explicitly stated that the total length of the sentence being less than the negotiated maximum was irrelevant, as the key element was the defendant’s awareness of all direct consequences at the time of the plea. The Court’s decision ensures that defendants are fully aware of the consequences of their guilty pleas, thus protecting their due process rights and ensuring the integrity of the plea bargaining process.